O.M.C. Model

Organisation, Management and Control Model

Spea Engineering S.p.A. decided to adopt the Organisation, Management and Control Model specified under Legislative Decree No. 231 dated 8 June 2001 which introduced new principles of responsibility by the company for certain types of crimes.

The organisation and management model originally adopted by a resolution of the Board of Directors of Spea Engineering S.p.A. on 5 March 2003 was updated and integrated on the basis of the legislations which followed throughout the years, which expanded the category of administrative crimes specified under Legislative Decree No. 231/01.

The model adopted by Spea Engineering S.p.A. complies with the guidelines prepared by trade associations, and represents another step towards transparency and the sense of responsibility in relations within the company and with the outside world; at the same time providing the shareholders with the best guarantees for an efficient and correct management.

The Model is subdivided into a General Part (General Principles) and seven Special Parts – relative to “Crimes against Public Administration” (Special Part A), “Corporate crimes and private corruption” (Special Part B), “Market abuse” (Special Part C), “ Crimes committed through violation of accident prevention and health and safety protection law” (Special Part D), “Money laundering crimes” (Special Part E), “Computer Crimes” (Special Part F) and “Crimes committed through violation of Environmental law” (Special Part G)– which list the specific types of crimes covered by the Legislative Decree and the internal requirements to be complied with to prevent the risk of them occurring.